Episode 315 - Boeing Pays $51 Million for ITAR Violations
On January 30, 2025, the CFPB ordered Wise, an international remittance company, to pay almost $2.5 million in connection with allegations of illegal activities, including advertising inaccurate fees and failing to properly...more
The Financial Industry Regulatory Authority (FINRA) published guidance* to remind parties, attorneys, arbitrators, and mediators that the unauthorized disclosure of a Suspicious Activity Report (SAR) is a violation of federal...more
On December 19, 2023, the Fifth Circuit Court of Appeals vacated the SEC’s share repurchase disclosure rule, which required issuers to: (i) report daily aggregate share repurchase data on a quarterly basis, (ii) indicate if...more
On November 10, 2021, the SEC announced that it had instituted proceedings against a Wyoming-based decentralized autonomous organization (DAO) to halt its registration of two digital tokens, alleging that disclosure in the...more
Regulators expect companies to investigate actual or potential violations completely and to disclose the nature and scope of those violations completely, in order to obtain credit for their disclosures. Identifying violations...more
We’ve all heard the jokes about fine print before – the text is so small you could be agreeing to give the dealership your first-born child. However, for regulators the fine print is no laughing matter. The bottom line is...more
The SEC charged former Hertz CEO and Chairman Mark Frissora with aiding and abetting the company in its filing of inaccurate financial statements and disclosures....more
The CFPB announced that it has entered into a consent order with Main Street Personal Finance, Inc. and two subsidiaries (Main Street), each a small-dollar lender, to settle the CFPB’s allegations that Main Street (1)...more
Product innovation (including in pooled investment vehicles) is encouraged, but innovation must be consistent with the law. The US Commodity Futures Trading Commission’s (CFTC’s) Division of Swap Dealer and Intermediary...more
The Department of Justice recently announced updates to its Foreign Corrupt Practices Act Corporate Enforcement Policy. While the changes were relatively minor, the modifications underscored important principles surrounding...more
The latest HIPAA resolution agreement by the U.S. Department of Health and Human Services Office for Civil Rights (OCR) is a reminder that healthcare providers must take the high road when responding to unflattering online...more
The Office for Civil Rights (OCR) at the Department of Health and Human Services announced it reached a settlement with Elite Dental Associates of Dallas (Elite) to resolve a complaint alleging Elite impermissibly disclosed a...more
In a settled enforcement action, the SEC resolved allegations related to non-monetary transactions regarding certain Comscore transactions. The enforcement action also involved disclosures surrounding the number of...more
On April 15, 2019, a California Court of Appeal affirmed summary judgment for the employer in an action alleging class-wide violations of the hyper-technical provisions of the federal Fair Credit Reporting Act (FCRA)....more
On January 21, 2019, the French data protection supervisory authority (“CNIL”) fined Google €50 million (approximately $57 million) for violating the European General Data Protection Regulation (“GDPR”). ...more
The U.S. Court of Appeals for the Third Circuit has ruled that although the plaintiffs had plausibly alleged facts stating a claim that a debt collector had violated the Fair Debt Collection Practices Act (FDCPA) by not using...more
The CFPB announced last week that it has entered into a consent order with Triton Management Group, Inc., a small-dollar lender, to settle the CFPB’s allegations that Triton had violated the Truth in Lending Act and the...more
The FDCPA, through section 1692d(6), prohibits a debt collector from placing telephone calls to a debtor “without meaningful disclosure of the caller’s identity.” 15 U.S.C. § 1692d(6). The FDCPA also includes a “bona fide...more